We write to you with respect to licence applications for badger culls under the Government's policy on Bovine TB and badger control in England (2011).

Open letter to Natural England Chief Scientist Professor Tim Hill

The Natural England Science Advisory Council (or equivalent)

Dear Tim Hill

Tuesday 11th August 2015

The Natural England Board

We write to you with respect to licence applications for badger culls under the Government's policy on Bovine TB and badger control in England (2011). As far as we understand, the existing licences for the pilot zones in Gloucestershire and Somerset remain in force, and culling is set to continue in these areas subject to letters of authorisation from Natural England. There is also speculation that an additional licence application may have been lodged for a cull zone in Dorset.

We wish to register our professional opinion that before making any decision the Natural England Scientific Advisory Committee (or equivalent) and thence the Board of NE should re-examine the scientific evidence associated with the control of bovine tuberculosis. In particular, they should examine the role that badgers play in the epidemiology of the disease, the hard data around the success of badger vaccination and the potential adverse impacts of badger culling on the spread of bovine tuberculosis in cattle. The NESAC and Board should also very carefully consider the Independent Expert Panel’s report (April 2014) on the welfare of badgers in the pilot trials, the withdrawal of BVA support for the method of culling proposed and the growing veterinary voice calling for the badger cull to be abandoned (McGill et al. 2012, http://veterinaryrecord.bmj.com/content/171/14/353.3.extract ; Jones et al. 2013, http://www.ncbi.nlm.nih.gov/pubmed/23857538; Allen et al. 2013, Badger cull has no basis in science. The Independent, 4 June 2013; Abraham et al. 2014, http://veterinaryrecord.bmj.com/content/174/26/664.2.extract; Torgeson 2015, http://veterinaryrecord.bmj.com/content/176/12/315.2.short?rss=1; McGill et al 2015 Vet Times 45, No 31 August 3, p35).

We are pleased to see the evidence strategy and standards section on Natural England’s website, laying out its clear strategy on using evidence to weigh policy proposals (ref NE340).

We hope and trust that in particular your evidence-based work on this issue will be Fit For Purpose, Quality Assured and Transparent.

We would very much appreciate the opportunity to open a line of communication with the Scientific Advisory Council and Board for Natural England, and if possible, would like to meet and discuss the scientific evidence and professional opinion that continues to accrue against the continuation and roll-out of culling.

Our objections to the cull are manifold, but can be briefly summarised thus:

1. The scientific evidence - The majority of wildlife, bTB and veterinary scientists (Bateson et al 2012 http://www.theguardian.com/theobserver/2012/oct/14/letters-observer, McGill et al 2015) do not support badger culling in any area of England, including the former cull zones in Gloucestershire and Somerset.

2. The science categorically does not support widening the cull to new areas – Many areas within the government’s ‘high-risk zone’ for bovine TB, including Dorset, have seen a

statistically significant fall in bTB outbreaks over the two years during which culling was being carried out in Gloucestershire and Somerset. In Dorset, the number of bTB outbreaks has fallen from 36 to 20 during that period1. Indeed, across the west region there has been a year-on-year fall in the number of cattle slaughtered as a result of bovine TB policy of approximately 12% from 2012-2014. These reductions have occurred in the absence of badger culling across the vast majority of the region, and reflect improvements in Wales where badger culling has been rejected in favour of the introduction of stricter cattle measures and the use of badger vaccination in the Intensive Action Area. We, therefore, argue that there is no scientific reason to introduce culling when current controls are working.

3. Poor results from Gloucestershire - The contractors in both Gloucestershire and Somerset failed to achieve the cull targets set as conditions of their licences during the first year of culling. In Gloucestershire, the contractors also failed to meet the considerably reduced targets set for the second year. In both counties, the contractors failed to satisfy humaneness criteria set by the Independent Expert Panel with respect to controlled shooting (IEP 2014 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/300424/pb141 58-defra-response-independent-expert-panel.pdf).The failure to achieve cull targets has likely resulted in significant badger perturbation, which is known to increase the risk of spread of bovine tuberculosis between badgers, and by extension from badgers to cattle (Bourne 2007 http://webarchive.nationalarchives.gov.uk/20090330154646/www.defra.gov.uk/animalh/tb/is g/pdf/final_report.pdf; Carter et al 2007, http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2279223/). The failure to satisfy humaneness criteria raises serious animal welfare concerns relating to the impacts of controlled shooting.

4. Worrying increase in bTB in cattle outside the Somerset cull zone - This would appear to mirror the situation experienced during the Randomised Badger Culling Trial around proactively culled areas, where the incidence in bovine TB in cattle increased significantly (Bourne 2007). Scientists have suggested that this effect results from badger perturbation, and such impacts could be predicted from the results and subsequent analysis of the RBCT. These impacts have not been accounted for in the claims made by vet Roger Blowey and others for the efficacy of the pilot culls in terms of their impacts on TB incidence in cattle within the cull zones (Blowey et al 2015 http://veterinaryrecord.bmj.com/content/176/8/208.short?rss=1), claims that have been rejected in the veterinary press (eg Torgerson et al 2015) and also in live debate with Prof John Bourne (at the Badger Trust AGM 2015).

5. Ethics and humaneness - The IEP report of April 2014 concluded that the pilot culls in year one failed in terms of humaneness (as well as efficacy).

6. Lack of veterinary support - Citing concerns over the lack of humaneness, the British Veterinary Association has withdrawn support for the controlled shooting of badgers. In spite of this, the method remains available to the contractors in the two zones.

7. Lack of public support - Recent polls in the cull areas suggest that public opposition to the rolling out of badger culling remains high ( http://www.westerndailypress.co.uk/polls )

8. Vaccination of badgers works, obviating the need for any cull - The latest science has conclusively demonstrated the effectiveness of vaccinating wild badgers, which makes them

76% less likely to develop progressive TB (according to “dual testing” approximating to tests for progressive infection). Due to ‘herd immunity’, vaccination of one-third of adults in a sett makes it 79% less likely for unvaccinated cubs to catch TB, according to an even more sensitive panel of tests approximating to testing for infection per se.

9.The Chief Veterinary Officer for Wales has reported that “incidents of TB have fallen by 28%” without badger culling ( http://www.bbc.co.uk/news/uk-wales-33622465) but with cattle-based measures and badger vaccination.

10. The badger cull policy has been overwhelmingly defeated twice in Parliament on a free vote.

11. Lack of a thorough Disease Risk Analysis (DRA) - The risks of badger shooting include not only perturbation of badgers with concomitant risks of bTB spread to neighbouring areas, but also contamination of woodland with bTB infected blood and body tissues. We have previously asked for the Disease Risk Analysis for the pilot projects, and for the use of free-shooting of badgers in particular. None has been forthcoming, and we suspect that no thorough DRA was ever conducted for the policy. We have submitted a separate FOI request regarding the missing DRA. We are also concerned that the wider environmental impacts of badger removal on other threatened species and protected areas, and, in particular, the possibility of sympatric mesopredator release within the cull zones, have not been sufficiently evaluated or addressed; such evaluations are a requirement of the Habitats and Birds Directives and the Conservation of Habitats and Species Regulations 2010, and of the Convention on the conservation of European wildlife and natural habitats (Bern Convention).

12. Spiralling costs - Each dead badger killed in the pilot culls has cost the public purse over £5000 including policing (http://www.bbc.co.uk/news/uk-england-30058872). Much of this spiralling cost is due to the unpopularity of the cull, which increases policing and logistics costs.

13. NESAC called for the cull to be immediately stopped in 2013 - I am sure you are only too well aware of the expert opinion given by former NESAC Chair Prof David Macdonald, that the cull should have been stopped back in 2013.

In summary, we strongly request that the NESAC and Board takes full account of the science, logistics, ethics and probity of any continued or extended culling of badgers, and examines the policy in the light of its lack of a science base, its ineffectiveness, its lack of humaneness, public opposition and spiralling costs.

It is our view that this policy does not represent an ethically sound, scientifically valid, or fiscally prudent method of controlling bovine tuberculosis. Natural England is the body the public looks to in order to ensure government policy does not harm wildlife and wild spaces. It is incumbent on Natural England to fully consider the evidence before proceeding to endorse a failing policy which will cause untold suffering to badgers and continuing hardship for dairy farmers by failing to tackle bTB.

We analysed data from the Government’s bTB website on herd breakdowns and continuing herd breakdowns, happening from before the start of the cull in 2013 and comparing those figures to those from the current 2015 situation. We completed the analysis, using Poisson tests, on data from in and around both cull zones and also from the proposed cull zone in Dorset.

Dorset – Analysis of data collected (independently from government) from the bTB website indicates a drop from 36 to 20 affected herds, which would represent a statistically significant (p<0.05) drop in bTB breakdowns in Dorset without badger culling. However, we add the caveat that although the fall in Dorset does appear statistically significant, there are other factors such as the numbers of tests carried out, time of year, and the way herds are counted as a “breakdown", or not, which all affect the apparent or reported figures. Nevertheless, on the Government’s own data, a statistically significant fall in Dorset may well have occurred. Cull Zones Bovine TB rates today among cattle within the cull area in Gloucestershire and Somerset have remained similar to pre-cull rates, although as afore-mentioned there would appear to be a marked increase in TB breakdowns outside the cull zone in Somerset.

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